Justia Criminal Law Opinion Summaries

In 1991, a jury convicted an individual of rape, sexual abuse, and abduction based on the testimony of the victim, who identified her attacker after encountering him twice following the assault. The incident occurred outdoors, and the victim described being attacked by a teenager whom she did not know. Physical evidence was collected at the hospital, but initial forensic testing at the time found no semen or foreign hairs linking the defendant to the crime. Despite the lack of biological evidence, the victim’s identification was central to the prosecution’s case, and the jury returned a guilty verdict.After exhausting direct appeals, the convicted individual sought post-conviction DNA testing decades later, alleging that advances in technology could yield exculpatory results. DNA testing was conducted on the biological evidence collected from the victim, including her underwear and swabs. The new tests found no male DNA on most items and excluded the defendant as a contributor to a partial DNA mixture found on the underwear. The individual then petitioned the Supreme Court of Virginia for a writ of actual innocence, arguing both the absence of his DNA and new non-biological evidence, including a declaration about the victim’s cognitive health and research on eyewitness identification.The Supreme Court of Virginia reviewed the petition under the statutory standard requiring the petitioner to show, by a preponderance of the evidence, that no rational factfinder would have found proof of guilt beyond a reasonable doubt in light of the new evidence. The Court held that the new DNA results did not definitively link or exclude the defendant from the crime and that the non-biological evidence was speculative and collateral. The Court concluded that the petitioner failed to meet the statutory burden and dismissed the petition for a writ of actual innocence. View "In Re: Hargrove" on Justia Law

The case concerns a defendant who pleaded guilty in 2012 to multiple sex offenses involving his minor children. He was sentenced to ten years in state prison followed by ten years of probation, with mandatory global positioning system (GPS) monitoring as a condition of probation under Massachusetts law. The statute required GPS monitoring for the entirety of his probation, but at the time of sentencing, no specific exclusion zones were established. After serving his prison sentence and two years of probation with GPS monitoring, the defendant sought relief from the GPS monitoring condition, arguing that it was unreasonable and unconstitutional, particularly due to its ten-year duration.After the Supreme Judicial Court’s decision in Commonwealth v. Feliz, which required individualized judicial findings regarding the reasonableness of GPS monitoring as a probation condition, the defendant filed a motion in the Superior Court for such an individualized assessment. The Superior Court judge denied the motion, finding that the Commonwealth had shown continued GPS monitoring was reasonable, based in part on the defendant’s classification as a level three sex offender and the victims’ statements about ongoing harm. However, the judge did not make findings regarding the reasonableness of the specific ten-year duration of GPS monitoring.The Supreme Judicial Court of Massachusetts reviewed the case on direct appellate review. The Court held that a judge must consider the duration of GPS monitoring in evaluating its reasonableness under the Massachusetts Declaration of Rights. The holding clarified that a judge may only impose GPS monitoring for a duration found to be reasonable, even if that period is less than the statutory term of probation. Because the Superior Court judge did not evaluate the ten-year duration, the Supreme Judicial Court vacated the order denying the defendant’s motion and remanded for further proceedings consistent with its opinion. View "Commonwealth v. Arnold" on Justia Law

The case involved a defendant who, while driving a sport utility vehicle (SUV) without a license, struck and fatally injured a pedestrian at an intersection in Waterbury, Connecticut. The defendant fled the scene without stopping. Several miles away, after the SUV broke down and partially blocked a residential driveway, the defendant, with the help of the homeowner and a taxi driver, pushed the damaged SUV into the driveway, leaving it at the front of other vehicles with its damaged front end fully visible from the street. The defendant did not attempt to hide the SUV further, nor did he inform the homeowner of the accident.A jury in the Superior Court for the judicial district of Waterbury found the defendant guilty of evasion of responsibility in the operation of a motor vehicle and tampering with physical evidence, based on the state’s theory that the defendant concealed the SUV to impair its availability in a criminal investigation. The Appellate Court affirmed the convictions, holding that a rational juror could find the act of concealment based on the context and circumstances, including the defendant’s flight from the scene and the temporary abandonment of the SUV in a private driveway.On further review, the Supreme Court of Connecticut concluded that the evidence was insufficient to establish concealment under General Statutes § 53a-155 (a). The court held that simply leaving the SUV in a visible spot at the front of a driveway, where its damage was apparent from the street, did not constitute concealment as required by the statute. The Supreme Court reversed the tampering conviction, directing the trial court to enter a judgment of acquittal on that charge and leaving resentencing, if any, to the trial court’s discretion. The remaining conviction was affirmed. View "State v. Bolden" on Justia Law

The essential facts of this case involve an individual who was convicted in Mississippi state court for failing to pay child support, an offense punishable by up to five years in prison but for which he ultimately received only probation. After repaying the owed child support and completing probation, the individual was later indicted under federal law, specifically 18 U.S.C. § 922(g)(1), which prohibits firearm possession by anyone previously convicted of a crime punishable by imprisonment for more than one year. The predicate offense for the federal charge was the non-payment of child support.In the United States District Court for the Southern District of Mississippi, the defendant twice moved to dismiss the indictment, arguing that § 922(g)(1) was unconstitutional as applied to him, among other constitutional challenges. The district court denied both motions. The defendant subsequently pleaded guilty pursuant to a plea agreement that preserved his right to appeal the Second Amendment issue, leading to this appeal before the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit reviewed the case and concluded that, under the historical inquiry required by the Supreme Court’s decision in New York State Rifle & Pistol Association v. Bruen, there is no historical tradition supporting the permanent disarmament of a person convicted solely of non-payment of child support, particularly where the debt had been repaid and probation completed. The court rejected the government’s analogy between debtors and thieves, noting that founding-era practices treated debtors differently, allowing for temporary disarmament only until the debt was paid. The Fifth Circuit therefore held that the application of § 922(g)(1) to the defendant violated the Second Amendment and reversed the conviction, remanding for further proceedings consistent with its opinion. View "United States v. Cockerham" on Justia Law

A man living in Muncie, Indiana, was charged with supplying another individual with counterfeit oxycodone pills (M30s) containing fentanyl, which were then sold to a seventeen-year-old who died from a fentanyl and cocaine overdose. The accused regularly sold M30s to the intermediary, who also obtained such pills from other sources. After the fatal incident, police recovered part of an M30 pill from the victim’s nightstand. During the investigation, the intermediary initially told police that the accused was the supplier of the fatal pills but later recanted, identifying another supplier. The State, planning to use the intermediary’s testimony, withdrew its immunity offer when the intermediary changed his account and decided not to call him as a witness, knowing he would invoke his right against self-incrimination.At the bench trial in Delaware Circuit Court, the prosecution introduced, over objection, the intermediary’s prior statement to police implicating the accused, but the defense was not given an opportunity to cross-examine the intermediary. The court found the accused guilty of multiple charges, including a Level 1 felony for aiding in dealing a controlled substance resulting in death. On appeal, the accused challenged the Level 1 felony conviction, arguing a violation of his Sixth Amendment right to confront the witness. The State conceded this violation but argued that the error was harmless. The Indiana Court of Appeals agreed with the State and affirmed the conviction.The Indiana Supreme Court granted transfer and reviewed whether the constitutional error was harmless beyond a reasonable doubt. The court concluded that the admission of the statement was not harmless, as it was the only direct, non-cumulative, and uncorroborated evidence linking the accused to the fatal pills, and the defense was denied cross-examination. The court vacated the Level 1 felony conviction and remanded for a new trial on that charge. View "Taylor v. State of Indiana" on Justia Law

Federal law enforcement began investigating the defendant after a wiretap of an associate’s phone implicated him in drug trafficking outside Chicago. The investigation revealed that the defendant, a convicted felon, was likely involved in significant drug transactions and was concerned about being targeted for a robbery. He was overheard discussing that he possessed a firearm for protection. Surveillance observed him using countersurveillance driving maneuvers, prompting agents to initiate a stop. During the stop, the defendant failed to comply with commands, resisted a frisk, and was ultimately found to have a handgun in his pocket.The United States District Court for the Northern District of Illinois, Eastern Division, considered and denied the defendant’s motion to suppress the firearm, finding that the officers had reasonable suspicion for the stop and that their use of force did not convert the encounter into an arrest without probable cause. The case proceeded to trial, where the jury found the defendant guilty of being a felon in possession of a firearm. The district court also denied the defendant’s posttrial motions for acquittal and a new trial. At sentencing, the court declined to enhance the sentence under the Armed Career Criminal Act (ACCA), concluding that the defendant’s prior Illinois conviction for voluntary manslaughter was not a qualifying predicate offense.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the conviction, holding that the officers had reasonable suspicion and their conduct was justified under the circumstances. The court also found the evidence at trial was sufficient to support the verdict and that the district judge’s evidentiary rulings did not merit a new trial. However, the Seventh Circuit vacated the sentence, holding that the defendant’s 1982 Illinois voluntary manslaughter conviction qualifies as a violent felony under the ACCA, and remanded for resentencing. View "USA v Edwards" on Justia Law

The case involves a defendant who was charged with multiple crimes related to the production, possession, and distribution of child pornography involving her fourteen-year-old sister. Law enforcement initially investigated the defendant’s husband, but their attention turned to the defendant after she admitted to possibly sending inappropriate photos of her sister to her husband. Subsequent forensic analysis uncovered additional incriminating evidence. Both the sister and husband testified regarding the abuse. The defendant’s primary defense was that she acted under duress due to severe abuse by her husband.In the United States District Court for the Southern District of Georgia, the defendant sought to introduce statements she made to a psychologist, Dr. Reynolds, as part of her duress defense. Dr. Reynolds, who had not practiced clinical work in a decade and was retained specifically to evaluate the defendant in anticipation of litigation, diagnosed her with a dissociative disorder. The government moved to exclude as hearsay those statements made by the defendant to Dr. Reynolds concerning her husband's alleged abuse, arguing that they did not meet the requirements of Federal Rule of Evidence 803(4). The district court agreed, finding the statements were not made for the purpose of medical diagnosis or treatment, but rather to prepare for trial. The court alternatively excluded the statements under Rule 403 due to prejudicial effect. After this ruling, the defendant entered a conditional guilty plea, preserving her right to appeal the evidentiary ruling.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and its factual findings for clear error. The Eleventh Circuit held that statements made to a medical expert retained for litigation, not for genuine medical diagnosis or treatment, do not qualify for the hearsay exception under Rule 803(4). The court found no error in the district court’s exclusion of the statements and affirmed the lower court’s decision. View "USA v. Keegan" on Justia Law

A woman was convicted of misdemeanor embezzlement in November 2016 and placed on three years’ probation. Eleven months into probation, she was accused of committing new fraud, and by December 2017, the probation department reported a violation to the trial court. Thirteen months after her probation began, the court summarily revoked her probation and set a hearing on the violation. That hearing was continued several times, sometimes at her request, and ultimately was never held. Meanwhile, in 2021, a new law—Assembly Bill 1950—shortened most misdemeanor probation terms to one year and applied retroactively.After the new law took effect, the woman moved to terminate her probation, arguing her term should be considered expired by operation of law under the revised statute. The People opposed, citing prior case law and statutory provisions that allow courts to retain jurisdiction over violations that occurred during the original term. The Contra Costa County Superior Court denied her motion, and the Appellate Division of the Superior Court denied her petition for a writ of mandate without explanation. She then sought relief in the California Court of Appeal, which initially denied her petition as well.Following reconsideration ordered by the Supreme Court of California in light of its decision in People v. Faial, the California Court of Appeal, First Appellate District, Division Three, concluded that the new law applied retroactively and that the woman’s probation expired by operation of law one year after it began. Because the trial court did not revoke probation within that new, shorter period, it no longer had jurisdiction to adjudicate the alleged violation. The Court of Appeal granted her petition, ordering termination of her probation and directing the lower courts to issue the necessary orders. View "Kuhnel v. Appellate Division" on Justia Law

A man was involved in an altercation in a McDonald’s parking lot, during which he struck and shot another individual. Surveillance footage captured the incident, and the state charged him with two counts of felonious assault, each carrying firearm specifications. Prior to trial, his attorney requested a jury instruction on self-defense. The trial judge, after viewing the video, indicated skepticism about granting the instruction, telling the defendant that he likely would not qualify for a self-defense instruction because the evidence suggested he may have initiated the altercation. The defendant expressed concern that without the instruction, a fair trial would not be possible, but the judge repeatedly allowed him opportunities to consult with counsel and emphasized that the decision to plead guilty was his alone.Subsequently, the defendant agreed to plead guilty to a reduced charge of aggravated assault with a firearm specification, in exchange for dismissal of the second count and a recommended aggregate sentence of four years. During the plea colloquy, the defendant again voiced his desire for the self-defense instruction and his sense of being “put in a box,” but ultimately confirmed to the court that his plea was voluntary.The First District Court of Appeals reviewed the case after the defendant appealed, arguing that the trial court’s misstatements regarding Ohio’s self-defense statute and its premature indication it would not give the self-defense instruction rendered his plea involuntary and unknowing. The appellate court held that these errors did not invalidate an otherwise valid plea.The Supreme Court of Ohio affirmed, holding that when a trial court complies with Ohio Criminal Rule 11 requirements, even erroneous legal statements or pretrial rulings on ancillary matters do not render a guilty plea unknowing, unintelligent, or involuntary. The court found no violation of Rule 11 and thus upheld the conviction. View "State v. Gowdy" on Justia Law

A man was originally convicted of felony burglary for breaking into a bar in Montana and received a twenty-year prison sentence with five years suspended. After serving time and being released, he began the suspended portion of his sentence. The State later filed a petition to revoke his suspended sentence based on several alleged probation violations, including failing to register as a sex offender. While represented by counsel, he admitted to the failure-to-register allegation, and the court set a dispositional hearing to determine the consequences.The Montana Ninth Judicial District Court presided over the revocation proceeding. At the dispositional hearing, the man appeared without counsel after his attempts to retain private counsel failed and after his appointed counsel was allowed to withdraw. He requested reappointment of a public defender but none was assigned before the hearing. The court conducted no inquiry into whether he knowingly and voluntarily waived his right to counsel and proceeded with resentencing him to five years in prison. The man appealed, arguing he was denied his right to counsel at a critical stage and that he did not waive that right.The Supreme Court of the State of Montana held that the district court erred by conducting the dispositional hearing and resentencing without counsel and without a valid waiver of the right to counsel. The Court found this to be a structural error requiring automatic reversal, noting the man’s consistent efforts to obtain representation and the absence of any meaningful waiver inquiry. The Court vacated the dispositional order and remanded for a new hearing at which the man must be represented or must validly waive representation. The Court declined to resolve his request to withdraw his earlier admission, leaving it for further proceedings if appropriate. View "State v. Lambert" on Justia Law